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requested in the enclosed subpoena, please accept this letter (in lieu of a subpoena) as our written request for the e-mail correspondence of inmate Jeffrey Epstein (76318-054) from July 6, 2019 through July 11, 2019 — excluding any correspondence between Epstein and the following attorneys: Marc Fernich a, Ma
t for the e-mail correspondence of inmate Jeffrey Epstein (76318-054) from July 6, 2019 through July 11, 2019 — excluding any correspondence between Epstein and the following attorneys: Marc Fernich a, Martin Weinber and Ma and Reid Weingarten Moreover, if you intend to disclose the existence of thi
n request for the e-mail correspondence of inmate Jeffrey Epstein (76318-054) from July 6, 2019 through Ju
required if the requested records are (1)produced b on or before the return date to Special Agent Eric Blachman and/or Assistant U.S. Attorney at: U.S. Attorne 's rim . , Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: or via email at ; and (2) accompanied by an executed
ersonal electronic devices, whether in the United States or any foreign jurisdiction. 3. The "Litigation" means the civil lawsuit filed by against Jeffrey Epstein on behalf of plaintiff under the case caption Jane Doe No. 2 v. Epstein, No. 08 Civ. 80119 in the United States District Court for the Southern Di
ion. 3. The "Litigation" means the civil lawsuit filed by against Jeffrey Epstein on behalf of plaintiff under the case caption Jane Doe No. 2 v. Epstein, No. 08 Civ. 80119 in the United States District Court for the Southern District of Florida. 4. Where possible, please produce the records requeste
gation" means the civil lawsuit filed by against Jeffrey Epstein on behalf of plaintiff under the case c
N.B.: Personal appearance is not required if the re uested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attorne 's Office. Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: or via email at ; and (2) accompanied by an executed
12 WL 5395249 (S.D.N.Y. Nov. 5, 2012) 2 iii EFTA00097333 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 Rules Fed. R. Civ. P. 24(b) 4 Fed. R. Civ. P. 26(c) 13 Fed. R. Cr
is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then compelled Maxwell, over objection, to answer irrelevant and highly prejudicial person
LES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
nt to Suppress All Evidence Obtained from the government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following: U.S. U.S. Attorne 's Office, SDNY s/ Christian R. Everdell 15 EFTA00097350
From: (USANYS) [Contractor]" •MIMMIIIM> To: SANYS)" alMIE> Cc: ' SANYS USANYS)" Subject: Re: Jeffrey Epstein, Blackmail and a Lucrative `Hot List' - The New York Times Date: Sun, 01 Dec 2019 16:08:21 +0000 SANYS The story sure makes it seem like the guy (
IE> Cc: ' SANYS USANYS)" Subject: Re: Jeffrey Epstein, Blackmail and a Lucrative `Hot List' - The New Y
YS)" alMIE> Cc: ' SANYS USANYS)" Subject: Re: Jeffrey Epstein, Blackmail and a Lucrative `Hot List' - T
ive `Hot List' - The New York Times Date: Sun, 01 Dec 2019 16:08:21 +0000 SANYS The story sure makes it seem like the guy (Kessler) is a scammer. U.S. Attorne 's Office, SDNY > On Dec 1, 2019, at 9:42 AM (USANYS) alMINE> wrote: > I spoke to Julie Brown about this guy. Even she was skeptical. > Sent from my
Entities connected to both Jeffrey Epstein and U.S. Attorne 's

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSONthe Southern District
LOCATION
Geoffrey S. Berman
PERSON
David Boies
PERSONSt. Andrew's
ORGANIZATION
Foley Square
LOCATIONCity of New York
LOCATION
Plaza
ORGANIZATIONOffice, Southern District
ORGANIZATION